1. Who We Are
When we refer to "CIEL" or "we" or "us" in this privacy policy, we mean ‘CIEL - The Open Sky Co.’ and any associated entities, subsidiaries, or partners. This policy reflects the way we handle personal information in the context of our investment activities, portfolio management, innovation partnerships, and global engagements.

2. Application of This Privacy Policy
This privacy policy governs the personal information we collect in connection with:

- Our website (https://www.ciel.space/) and online platforms

- Investor and partner communications

- Portfolio project engagement and due diligence

- Events, marketing, and business development activities

- Subscriptions to updates, research, or investor reports

- Third-party service providers (analytics, IT, advisory, legal, and payment services)

3. Purpose of This Policy

CIEL respects your privacy and is firmly committed to protecting the confidentiality, integrity, and security of your personal information in compliance with the **General Data Protection Regulation (GDPR)** and other applicable data protection laws.

4. Contact Information Our Information Officer oversees compliance with this policy and all related data governance matters:

Information Officer
Email: ip@ciel.space

5. Privacy and Security
We apply strict organizational and technical measures to safeguard personal information, including:

- Encrypted communication channels and secure servers

- Access restriction to personal data on a need-to-know basis

- Data storage with regular integrity testing and backups

- Anti-virus, anti-malware, and firewall protections

- Continuous review of our cyber and data resilience measures

6. Personal Information Collection
Depending on your interaction with CIEL, we may collect:

- Contact details (name, email, professional role)

- Identification data required by law during investor onboarding or due diligence

- Information voluntarily provided in communications or applications to portfolio initiatives

- Financial, compliance, or investment-related details when legally required

- Research or stakeholder interest data relevant to partnership discussions

We do not seek to collect sensitive personal data except where required strictly by law or with explicit consent.

7. Information Accuracy
To maintain compliance and respond effectively to your requests, please ensure that any personal information you provide is current and accurate.

8. Purpose of Processing Personal Information
CIEL processes personal data for:

- Investor onboarding, capital calls, and compliance processes

- Portfolio investment management and project evaluation

- Responding to queries, business development, and partnership outreach

- Communications regarding research, insights, and strategic updates

- Meeting regulatory, risk, and anti-fraud requirements

- Security, operational, auditing, and record-keeping purposes

9. Direct Marketing
We respect your preferences. You may opt out of receiving communications about CIEL activities, investment opportunities, or portfolio updates by unsubscribing or contacting ip@ciel.space.

10. Disclosure of Personal Information
We may share personal information with:

- CIEL affiliates, portfolio companies, or investment partners globally

- Professional advisors (legal, financial, compliance, IT, consulting) assisting CIEL

- Regulatory and supervisory authorities as legally mandated

- Third parties if CIEL undergoes reorganization, investment syndication, or partnership restructuring

11. International Data Transfers
As a global-facing entity, CIEL may transfer your personal data across borders. Such transfers will always comply with GDPR, applying safeguards such as Standard Contractual Clauses or equivalent legal mechanisms.

12. Your Rights
Under GDPR you have the right to:

- Request access to the personal information we hold about you

- Request correction of incomplete or inaccurate information

- Request deletion in certain circumstances (“right to be forgotten”)

- Object to processing under legitimate interests

- Request temporary restriction of processing during disputes

- Withdraw consent at any time for processing based on consent

Requests can be made directly to ip@ciel.space.

13. External Links
Our website and communications may feature links to third-party websites. CIEL is not responsible for their privacy practices. We advise you to review their policies before providing them with personal data.

14. Complaints
If you are dissatisfied with how we handle your personal information, please first contact our Information Officer at ip@ciel.space. You also have the right to lodge a complaint with your local data protection authority or, in the EU, with a supervisory authority under GDPR.

15. Policy Updates
This policy will be reviewed periodically to reflect changes in regulation, technology, and CIEL’s operational framework. The latest version will always be posted at https://www.ciel.space/privacypolicy